Do Employers Comply with Pay Transparency Requirements in Job Postings?

Richard Audoly and Roshie Xing

Over the past few months, New Jersey and Vermont have joined a growing number of U.S. states in requiring employers to include an estimated salary range in their online job listings. Has this push for greater pay transparency been effective? In this post, we use granular data on U.S. job postings from Lightcast to assess employers’ compliance with these new regulations. Focusing on the jurisdictions that adopted pay transparency laws early on, we find that many employers ignore pay transparency requirements; roughly a quarter of job listings covered by these laws fail to include salary information.

Aggregate Pay Transparency in Online Job Ads 

Across the United States, the monthly share of online job postings with pay information has risen dramatically, from an average of 15 percent before January 2018 to approximately 53 percent since January 2024. In the Lightcast data, pay information is recorded in the form of an annualized upper and lower bound of advertised salary. For most jobs posted in recent years, pay information is an actual range. The share of job postings with the same lower and upper bounds (a “point salary”) has plateaued at about 15 percent, as shown by the red line in the chart below. While researchers have suggested potential explanations for this overall trend, notably the inclusion of an estimated salary range by some major job listing platforms, we focus on recent legislation requiring employers to include an expected starting pay range in their job listings. How has pay transparency in online job ads evolved in the jurisdictions that have enacted these requirements?  

Pay Transparency Requirements 

To date, ten states, the District of Columbia, and multiple local jurisdictions have adopted such pay transparency laws; the most recent states to do so—New Jersey and Vermont—began implementation in June and July of 2025, respectively. Broadly, these laws require firms that advertise jobs externally to include a “good faith” estimate of the salary or wage range that they expect to pay. These laws are frequently proposed and written with the aim of addressing pay disparities. For example, Massachusetts’ fact sheet for employers begins by stating that its pay transparency law was signed “to increase equity and transparency in pay in the Commonwealth,” with pay transparency cited as “one of the best tools to close gender and racial wage gaps.” 

In this post, we focus on the three earliest states to implement these laws—Colorado (January 2021), California (January 2023), and Washington (January 2023)—in addition to New York City (November 2022); combined, these four jurisdictions account for about 20 percent of all job postings across the United States.  

The chart below shows the monthly share of job postings with salary information in these four jurisdictions; for comparison, the “other” line tracks the average percentage for all other states excluding New York. We remove non-New York City postings from the New York State data, as the state began implementation of a parallel pay transparency law in September 2023. The dashed lines demarcate when legislation enforcement began. We can see the impact of pay transparency requirements: in the month when regulations were implemented, the share of postings with salary information increased by an average of 20 percentage points, while there was a similar 27 percentage point increase across the entire January 2020-March 2025 period for states without such a law. We can also see that the post-transparency-legislation shares do not reach 100 percent. However, given that businesses with few employees are exempt from pay transparency requirements, to what degree does that shortfall reflect noncompliance? 

Expected versus Observed Compliance 

Exceptions for small employers, temporary help agencies, and narrow cases of remote work imply that employers could be in full compliance even if not all postings include salary information. Specifically, employers with a national headcount of fewer than fifteen workers are excluded from California’s and Washington’s pay transparency requirements. This threshold is even lower for employers in New York City (four) and Colorado (one employee in the state). In the panels below, the light blue lines show the evolution of the monthly share of job postings with salary information for each state, plotted against estimates of the expected share under full compliance.  

We use two supplementary data sources to construct these benchmarks. First, we use the Bureau of Labor Statistics’ Job Openings and Labor Turnover Survey (JOLTS) estimates of job openings by establishment size class to approximate the share of vacancies belonging to establishments with at least ten employees between January 2023 and April 2025. The resulting estimate (80.4 percent) is plotted in the panels below as a red line.  

Observed Compliance with Pay Transparency Laws Falls Short of Compliance Expected from Laws’ Firm Size Exemptions

Sources: Lightcast; Bureau of Labor Statistics, JOLTS; authors’ calculations.
Notes: The Bureau of Labor Statistics does not report establishment size estimates by state, so we assume that this distribution is constant across states. Additionally, the laws’ size restrictions are based on firm (national) employment rather than local establishment sizes. 

For a more refined approach, we turn to firm characteristics identified by Lightcast, which include firm size classes. In the panels above, the gold line represents the average monthly share of Lightcast job postings in each state originating from firms with at least eleven employees. Although there is minor variation across the four states, this share is approximately 87 percent. From the substantial gap between the light blue and gold lines, we can observe that while actual compliance with pay transparency laws is high, it falls short of our back-of-the-envelope estimation of expected compliance.  

Even when breaking out the share of compliant postings by firm size class in the charts below, we fail to observe 100 percent compliance. If anything, the largest firms—which should all be bound by pay disclosure laws—are least likely to voluntarily post salary information in job postings prior to regulations. After pay disclosure laws are implemented, the shares of job postings with salary information from firms in the three largest size classes are in line with the share from firms with ten or fewer employees. Taken together, the online postings data provided by Lightcast suggest that, as of January 2025, approximately 24 percent of ads do not comply with pay transparency requirements. Echoing these findings, several jurisdictions, such as Colorado and New York City, have conducted violation investigations and issued notices or fines since these laws were passed.  

A Substantial Share of Firms Bound by Pay Transparency Laws Remain Noncompliant

Share of postings by firm size (number of employees)

Sources: Lightcast; authors’ calculations.

Conclusion 

Across a range of jurisdictions, we document that pay transparency in job postings remains incomplete several years after legal mandates came into force: nearly a quarter of ads bound by mandates in early adopting states still omit wage information. The reasons for noncompliance, however, are still unclear. Are employers unaware of the new rules requiring pay transparency in job postings or do they actively withhold the expected salary? Tracking compliance only represents the first step toward understanding the response of employers to pay transparency regulations.  

Richard Audoly is a research economist in the Federal Reserve Bank of New York’s Research and Statistics Group.

Roshie Xing, a former research analyst at the Federal Reserve Bank of New York, is currently a first-year PhD candidate in economics at Stanford University.

 @article{
        AudolyXing2025,
        author={Audoly, Richard and Xing, Roshie},
        title={Do Employers Comply with Pay Transparency Requirements in Job Postings?},
        journal={Liberty Street Economics},
        note={Liberty Street Economics Blog},
        number={October 2},
        year={2025},
        url={ https://doi.org/10.59576/lse.20251002}
    }

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